This Personal Data Protection Policy ("Policy”) applies to the collection, use, disclosure, access to and correction, and care, of Personal Data (hereinafter defined) arising from the business operations of Esprimo Pte Ltd (hereinafter defined).
By interacting with Esprimo Pte Ltd, submitting Personal Data to Esprimo Pte Ltd, or signing up for any products or services offered by Esprimo Pte Ltd, you consent to Esprimo Pte Ltd, as well as its representatives and/or agents, collecting, using, disclosing and sharing amongst themselves Personal Data, and disclosing such Personal Data to other parties in the manner set forth in this Data Protection Policy.
This Policy supplements but does not supersede or replace any other consent which may have been previously provided to Esprimo Pte Ltd in respect of Personal Data. Consents given herein are in addition to any rights which Esprimo Pte Ltd may have at law to collect, use or disclose Personal Data.
Esprimo Pte Ltd may from time to time update this Policy to ensure that this Policy is consistent with Esprimo Pte Ltd future developments, industry trends and/or any changes in legal or regulatory requirements. Esprimo Pte Ltd remains committed to safeguarding Personal Data and being open about its Personal Data protection practices. To the extent permitted by law, you agree to be bound by the prevailing terms of this Policy as updated from time to time. The latest version of this Policy may be obtained from Esprimo Pte Ltd Data Protection Officer at the contact particulars provided in Clause 14 below.
- Purpose of Collection, Use and/or Disclosure of Personal Data
The reasons for using your personal data may differ depending on the purpose of the collection. Regularly we use your data for the following purposes and on the following legal grounds:
- We use your personal data in order to perform our contractual services or for the preparation of entering into a contract with you. If you register for our Events or if you contact us to register for our Events, we use your data to conduct our Events and make your participation in our Events possible. Information we use includes: information we need to contact you or otherwise communicate with you, e.g. to send you administrative information, registration and Event information to process your Event registration and participation; information for payments processing; information to respond to your comments and questions and provide customer service; if you are a registered user: information to manage and create your account.
- The usage of your personal data may also be necessary for our own business interests. For example, we may use some of your personal data to evaluate and review our Events and overall business performance, create financial statements, understand you and your preferences to enhance and individualize your experience and enjoyment of our Services, and improve our Services. If necessary, we may also use your personal data to pursue or defend ourselves against legal claims. We may use your personal data to provide you with individualized marketing. For instance, we deliver targeted advertising messages to you on our websites and elsewhere on the Internet. If you have participated in our Events before, we may use your email address to provide you with information on similar events.
- We use your personal data after obtaining your consent. In some cases, we may ask you to grant us separate consent to use your personal data. You are free to deny your consent and the denial will have no negative consequences for you. You are free to withdraw your consent at any time with effect for the future. If you have granted us consent to use your personal data, we will use it only for the purposes specified in the consent form.
Download Form to Withdraw Consent here.
- This also includes our marketing campaigns. If you sign up to our email newsletter or when providing us with your email address allow us to use this email address for email marketing, we will use your personal data in our email marketing campaigns. You may unsubscribe from our email newsletter at any time. You may also contact us via email, phone or mail at the addresses provided at the end of this document to request that we remove you from our email list.
- We use your personal data to comply with legal obligations. We are obligated to retain certain data because of legal requirements, for example, tax or commercial laws or we may be required by law enforcement to provide personal data on request.
- We will only use your personal data for the purposes for which we have collected them. We will not use your personal data for other purposes. We do not use your personal data for automated individual decision-making.
- Disclosure of Personal Data
As required in accordance with how we use it, we will share your personal data with the following third parties:
- Process your online registration application
- Respond to enquiries and requests from you or people you have authorized
- Inform you about events updates or partners promotions
- Conduct market research and customer satisfaction surveys
- Provide updates, offers, invitations to events and deliver advertising messages via SMS / MMS,
- Email or your mailing address with your prior consent or if otherwise permitted under local laws and regulations
- Emergency situations arising from incidents/accidents occurring during participation of any Esprimo Pte Ltd
- Service providers and advisors: Third party vendors and other service providers that perform services for us and on our behalf, which may include marketing campaign services, providing mailing or email services, text services related to the registration and organization of our Events, payment processing, data enhancement services, fraud prevention, web hosting, or providing analytic services. These third parties include: Timing Vendors… etc. Any such service providers will by appropriate data processing agreements be bound to only process the data on our behalf and under our instructions.
- Marketing Partners. We may disclose your personal data to our third-party sponsors and marketing partners (collectively, "Marketing Partners") to allow them to market their products or services to you, and measure the effectiveness of their marketing campaigns, promotions, endorsements and sponsorships or for other marketing purposes.
- Event Photographers. This event may be recorded and photographed. Your presence at this event is deemed as your consent to being photographed. Photographs and videos may be taken for news and publicity purposes.
Access to, Correction of and Accuracy of Personal Data
- The source providing Personal Data to Esprimo Pte Ltd shall ensure that the Personal Data provided is accurate and complete. The source shall also give Esprimo Pte Ltd notice in writing addressed to Esprimo Pte Ltd Data Protection Officer as soon as is reasonably practicable should it be aware that any Personal Data provided has been updated or changed.
Download Form for Correction Request here.
- Personal Data held by Esprimo Pte Ltd may, subject to the restrictions set out in the Act, be accessed, corrected or updated by making a request to Esprimo Pte Ltd Data Protection Officer at the contact particulars provided in Clause 14 below. Esprimo Pte Ltd reserves the right to charge a reasonable administrative fee for access to Personal Data.
Download Form for Access Request here.
List of Personal Data Collected
In the context of rendering our Services, we may collect personal data about you. This personal data regularly includes the following:
- If you register for an Event (Registration with a Registration Partners). Username, password, name, email address, phone number, address, birth date, gender, information on medical condition, emergency contact information, registration number and other information you provide during registration.
- If you contact us via our website, email, phone or mail. Name, email address, phone number, address and other information you provide.
- If you subscribe to our newsletter. Name, email address, marketing campaign information such as your reaction to our marketing and your interest in our Services.
- Information we collect during your participation of our Event. Information on your performance, such as your starting number, your place in the rankings, other information in the context of your ranking and any other information you provide us during the Event.
- Information we collect from social networks. When you interact with our Services through various social media, such as when your login through Facebook, Twitter, Instagram or other sites, we may receive information from those social networks including your profile information, picture, user ID associated with your social media account, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings.
Collection of Personal Data
- Most of the personal data we receive comes to us voluntarily from our users in the course of using our Services, such as when visiting our website, registering and participating in our Events or communicating with us. Esprimo Pte Ltd may collect your personal information when you:
- Register for any events organised by Esprimo Pte Ltd;
- Subscribe to our e-newsletters
- Contact us with an event or merchandise enquiry;
- Submit forms or applications to Esprimo Pte Ltd; (and/ or any of its related entities) (including but not limited to the Registration Form for xxx event name)
- Submit queries or requests to Esprimo Pte Ltd;
- Submit complaints;
- Provide feedback;
- Respond to Esprimo Pte Ltd.’s request to provide further information;
- Visit the event website;
- Submit your personal information to Esprimo Pte Ltd, for any other reasons; and
- Provide Esprimo Pte Ltd (and/ or any of its related entities) with any personal information relating to a third party (including but not limited to that of a dependent and/ or spouse), by submitting such information to us, you warrant and represent to Esprimo Pte Ltd that you have obtained the consent of that third party, to your providing Esprimo Pte Ltd with their personal information, for the respective purposes.
- Personal data we receive from others: We may receive personal data about users from third parties such as our Registration Partners, social media sites, Marketing Partners (as defined below) and law enforcement agencies.
Protection of Personal Data
- Esprimo Pte Ltd has implemented stringent measures to secure and protect your information. These include:
- Safeguards to prevent security breaches in our network and database systems
- Limits on access to information in our systems and the systems of our business partners and vendors
- Strict verification processes to prevent unauthorised access to information
- Proper disposal of confidential documents which are no longer needed through shredding machine
- In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose personal data may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Retention of Personal Data
- Esprimo Pte Ltd will dispose of or delete, as reasonably possible, or otherwise anonymise, any Personal Data as soon as it is reasonable to assume that the purpose for which the Personal Data was collected is no longer being served by retention of the Personal Data, and further, that retention is no longer necessary for legal or business purposes.
Transfer of Personal Data Overseas
Personal Data may be transferred to jurisdictions outside Singapore. For instance, Personal Data may be processed by Esprimo Pte Ltd, its agents and third parties providing services to Esprimo Pte Ltd, in jurisdictions outside Singapore. In this event, Esprimo Pte Ltd will comply with the terms of the Act.
Personal Data from Third Party Source
- This Clause 9 applies in respect of Personal Data about an individual which is obtained by Esprimo Pte Ltd from a source other than that individual (“Third Party Source”) .
- The Third Party Source hereby represents, undertakes and warrants to Esprimo Pte Ltd that:
- for any Personal Data of individuals that the Third Party Source is or will be disclosing to Esprimo Pte Ltd, whether directly or through an intermediary, the Third Party Source would have, prior to disclosing such Personal Data to Esprimo Pte Ltd, obtained the appropriate consent from the individuals whose Personal Data are being disclosed, to:
- permit the Third Party Source to collect, use and/or disclose the individuals' Personal Data to Esprimo Pte Ltd for the Permitted Purposes and in accordance with this Policy; and
- permit Esprimo Pte Ltd to collect, use and/or disclose the individuals' Personal Data for the Permitted Purposes and in accordance with this Policy;
- any Personal Data of individuals that the Third Party Source will be or is disclosing to Esprimo Pte Ltd is accurate and complete;
- the Third Party Source shall give Esprimo Pte Ltd notice in writing addressed to Esprimo Pte Ltd Data Protection Officer at the contact particulars provided in Clause 14 below as soon as is reasonably practicable should it be aware that: (i) any such Personal Data has been updated or changed after such disclosure; and/or (ii) any individual above has withdrawn such consent as set out at sub-Clause (a); and
- the Third Party Source shall otherwise assist Esprimo Pte Ltd to comply with the Acts
- Notwithstanding anything to the contrary, the Third Party Source undertakes to indemnify and at all times hereafter to keep Esprimo Pte Ltd, together with their respective officers. employees and agents (each an "Injured Party”), indemnified against any and all losses, damages, actions, proceedings, costs, claims, demands, liabilities (including full legal costs on an indemnity basis) which may he suffered or incurred by the Injured Party or asserted against the Injured Party by any Organisation (including without limitation the Third Party Source and its agents) whatsoever, in respect of any matter or event whatsoever arising out of, in the course of, by reason of or in respect of : (i) any breach of any of the terms in this Clause; and/or (ii) any act or omission by the Third Party Source that causes Esprimo Pte Ltd to be in breach of the Act.
- Where Esprimo Pte Ltd acts as data intermediary (as defined in the Act) that processes Personal Data on behalf of and for the purposes of another Organisation, Esprimo Pte Ltd shall only be subject to terms in the Act relating to protection of Personal Data and retention of Personal Data; and nothing in this Policy shall be deemed to impose on CSC Group a greater obligation than that prescribed under the Act.
- If any of the terms of this Policy becomes invalid, illegal or unenforceable in any respect under the law, the validity, legality and unenforceability of the remaining terms shall not in any way be affected or impaired.
- This Policy shall be construed in accordance with the laws of Singapore and all Organisations to which this Policy applies hereby submit to the non-exclusive jurisdiction of the Singapore Courts.
Withdrawal of Consent for the Collection, Use and/or Disclosure of Personal Data
- To keep you in control of your Personal Information and the communications sent to you, you may opt out of the following services:
- Receiving communications from Esprimo Pte Ltd and our affiliates about future events;
- Receiving news and updates on our events, promos and services.
- If you object to any of the above services for any reason, please direct such notices to Esprimo Pte Ltd Data Protection Officer at the contact particulars provided in Clause 14 below. Upon receipt of such notice, Esprimo Pte Ltd will inform you of the likely consequences of withdrawing your consent.
Contacting the Data Protection Officer
- For any question or concern relating to this Policy, please contact Esprimo Pte Ltd Data Protection Officer at:
Esprimo Pte Ltd
70 Ubi Crescent, #01-01, Ubi Techpark, Singapore 408570
For more information about PDPA, please visit the Personal Data Protection Commission's website at http://www.pdpc.gov.sg